The
following fact sheet was prepared by the ECAR Center staff. Once
prepared, each ECAR Center fact sheet undergoes a review process
with the applicable state environmental agency(ies). You can check
on the status of the review process here.
Please read the disclaimer on the status page. While we have tried
to present a summary of the essential information on this topic,
you should be aware that other items, such as local regulations,
may apply to you.

What You Need to Know

Antifreeze
is used as an engine coolant and commonly consists of ethylene glycol
or propylene glycol. Antifreeze breaks down over time and forms
acids that corrode a vehicle's cooling system. During its use, antifreeze
may become contaminated with traces of fuel, metal particles, and
grit. Benzene, lead, and other hazardous constituents may cause
used automotive antifreeze to be characterized as a hazardous waste.

The
New Hampshire Department of Environmental Services (DES) has prepared
a guidance document to help auto recyclers manage antifreeze. Much
of the information is included in the fact sheet below. You can
access the DES's "Waste Antifreeze: Management Requirements for
Handlers and Transporters," under Other Relevant Resources.

Regulations

Waste
Classification. Waste antifreeze may be managed
under New Hampshire's Universal Waste Rule. Universal wastes are
wastes that meet the definition of hazardous waste in the New Hampshire
hazardous waste rules, but which during accumulation and transport
pose a relatively low risk compared to other hazardous wastes. DES
has determined that antifreeze meets the universal waste criteria.

Generator
Status. If waste antifreeze is managed under
the universal waste rule, it does not need to be included in the
calculation of a hazardous waste generator's status. Universal wastes,
when recycled, are also not subject to the state's generator fee.

Universal
Waste Consolidation. You
may collect waste antifreeze from other sites or generators without
a permit, provided the facility meets the handler requirements covered
in the Universal Waste Rule, and complies with other applicable
federal, state, and local regulatory requirements.

Recycling/Disposal
Options and Prohibitions You do not need a permit if you recycle antifreeze on-site at your facility.
You may purchase an antifreeze distillation or filtration unit and
recycle your own antifreeze on-site, hire a contractor to come in
with a mobile recycling unit, or ship the antifreeze to a recycling
facility. Waste antifreeze may not be disposed of by throwing it
in the trash or pouring it down the drain.

Waste
Antifreeze Mixtures. Waste
antifreeze should not be mixed with used oil or other hazardous
wastes, such as gasoline or solvents. Waste antifreeze mixed with
any other material may lose its ability to be recycled and may be
subject to the full requirements of the state's hazardous
waste requirements. In order to avoid contamination of antifreeze
with other wastes, do not use collection equipment and storage containers
that have been previously used to collect other hazardous wastes
or materials, unless the equipment has been decontaminated. This
includes collection funnels, transfer pans or buckets, drums, and
tanks.

Filters
and Sludges. Any filters or sludges generated
from the antifreeze recycling process must be evaluated as to whether
they are hazardous wastes and managed accordingly. A recycling
contractor who removes a spent antifreeze filter and sludges from
a recycling unit at his or her own facility becomes the generator
of these wastes. If the contractor brings a mobile recycling unit
to your facility and removes a filter and sludges from the recycling
unit on-site, then one of the following options must be chosen:

The
recycling contractor becomes the generator of the spent filter and
sludges and transports them back to his or her site where he or
she will perform a hazardous waste determination.

The
contractor may leave the filter and sludges with the waste antifreeze
generator who then becomes the generator of the spent filter and
sludges.

Prior
arrangements should be made between the waste antifreeze generator
and the contractor as to which of these options will be chosen.
In either case, these wastes must be managed in accordance with
the state's hazardous waste rules.

Requirements
for Handlers. A
waste antifreeze "handler"
means:

A generator
of universal waste antifreeze; or

An
owner or operator of a facility that receives universal waste
antifreeze from other handlers, accumulates the antifreeze,
and sends the antifreeze to another handler or to a destination
facility.

Handlers
of universal waste antifreeze must either meet the following standards
or comply with the generator and/or facility requirements of the
state's hazardous waste rules.

Release
Prevention. You must manage waste antifreeze in a way that prevents releases
of antifreeze to the environment.

Quantity
Limits by Generator Status.

A Small
Quantity Handler may accumulate no more than a combined total
of 5,000 kilograms (11,000 pounds) of universal wastes on-site
at any one time. 5,000 kilograms of antifreeze is equivalent
to approximately 1,250 gallons.

A Large Quantity Handler may accumulate greater
than or equal to 5,000 kilograms, but less than 20,000 kilograms,
combined total of universal wastes on-site at any time.

A Very Large Quantity Handler may accumulate
greater than or equal to 20,000 kilograms, combined total of
universal wastes on-site at any time.

Storage
and Labeling. Accumulate
waste antifreeze in containers or tanks that are structurally sound,
compatible with the antifreeze, and are closed and sealed at all
times except when antifreeze is being added to or removed from the
container. The containers must not show evidence of leakage, spillage,
or damage. Containers stored outside shall be covered to prevent
precipitation from coming in contact with the waste.

Clearly
label or mark each container or tank of waste antifreeze with any
one of the following phrases: "Universal Waste - Antifreeze,"
or "Waste Antifreeze," or "Used Antifreeze."

Accumulation
Time Limits. Accumulate
waste antifreeze for no longer than one year from the date the waste
antifreeze is generated or received from another handler. Demonstrate
the length of time that the waste antifreeze has been accumulated
starting from the date the antifreeze became waste or was received.
You may make this demonstration by:

Marking
or labeling containers with the starting accumulation date;
or

Maintaining
an inventory system on-site that identifies the earliest date
that antifreeze was added to a container or was received from
off-site.

Training.
Ensure that all employees who handle
or have responsibility for managing waste antifreeze are thoroughly
familiar with the handling and emergency procedures appropriate
to antifreeze.

Response
to Releases. Immediately
contain and clean up all releases of antifreeze. Manage any residues
resulting from the clean up of antifreeze spills or leaks that exhibit
a characteristic of hazardous waste, in accordance with the state's hazardous waste rules.
The handler is considered the generator of the residues and other
clean-up waste and must meet state requirements.

Any
releases that pose a threat to human health or the environment must
be reported immediately to DES at 603-271-3899, or if after-hours
or the weekend, contact the New Hampshire Department of Safety Hazmat
Unit at 800-346-4009, 24 hours/day, and to the municipality in which
the release occurred.

Off-Site
Shipments. Handlers
are prohibited from sending or taking universal waste antifreeze
to a place other than another universal waste handler, an authorized
antifreeze recycling facility, or an authorized hazardous waste
facility.

Prior
to sending a shipment of waste antifreeze to another handler or
destination facility, the originating handler shall ensure that
the receiving handler agrees to receive the shipment. Shipments
must meet all applicable U.S. Department of Transportation regulations.

If
a waste antifreeze shipment is rejected by an intermediate handler
or destination facility, arrangements must be made by the originating
handler to receive the waste antifreeze back when notified that
the shipment has been rejected, or send the waste antifreeze shipment
to an alternate facility.

Exports.
A handler of waste antifreeze who
sends the antifreeze to a foreign destination must comply with the
requirements for international shipments as set forth in the state's
Universal Waste Rule.

Additional
Requirements for Large Quantity Handlers. A handler who plans to accumulate 5,000 kilograms
or more of combined universal wastes must comply with additional
large quantity handler requirements. These include notifying DES
prior to the start of this activity and obtaining an EPA Identification
Number, if one has not already been obtained. Records must be kept for three years on each shipment
of waste received or sent. These records must include the date of
each shipment, the quantities of each shipment, and the name and
address of the handler or facility from which waste antifreeze was
received or shipped to.

Additional
Requirements for Very Large Quantity Handlers. A handler who plans to accumulate
20,000 kilograms or more of combined universal wastes must comply
with the state's very large quantity handler requirements. You must:

Submit a notification form for each on-site location
where universal waste is accumulated.

Requirements
for Transporters. Transporters are not required to obtain
a New Hampshire hazardous waste transporter registration or use
a hazardous waste manifest for universal waste antifreeze, but must
meet all applicable US DOT regulations. Transporters are prohibited
from sending or taking waste antifreeze to a place other than another
handler, an authorized antifreeze recycling facility or an authorized
hazardous waste facility.

In
response to releases, transporters must immediately contain and
clean up all releases of antifreeze and manage any residues resulting
from the clean up of spills or leaks that exhibit a characteristic
of hazardous waste in accordance with the state's hazardous waste
rules. Any releases which pose a threat to human health or the environment
must be reported immediately to DES at 603-271-3899, Monday through
Friday, 8 am to 4 pm or to NH DOS Hazmat Unit at 800-346-4009, 24
hours/day, and to the municipality in which the release occurred.

Staging
During Transportation. Transporters
who remove universal waste antifreeze from their vehicles and stage
it temporarily are not required to obtain a hazardous waste transfer
facility permit, but are subject to US DOT regulations. Transporters
who stage universal waste antifreeze for more than 10 days must
also meet the universal waste handler requirements.

Exports.
Transporters taking waste antifreeze
to a foreign destination must comply with the requirements for international
shipments as set forth in the state's Universal Waste Rule.

Links
to the Regulations. Use
the following links to view the regulations pertaining to used antifreeze
management.

When
an inspector comes to your facility, there are certain things he
or she checks to see if you are in compliance with environmental
regulations. It makes good sense for you to perform a "self-audit"
and catch and correct problems before they result in penalties.
Also, there are some compliance incentives associated with self-audits
(see Audit Policy Page).

Use
the following list to audit your antifreeze storage areas and management
procedures.

Is used antifreeze stored in
drums, tanks or other containers that are in good condition? Accumulate waste antifreeze
in containers or tanks that are structurally sound, compatible
with the antifreeze, and are closed and sealed at all times except
when antifreeze is being added to or removed from the container.
The containers must not show evidence of leakage, spillage, or
damage. Containers stored outside shall be covered to prevent
precipitation from coming in contact with the waste.

Are you storing the antifreeze
for the permitted accumulation time? Do not store antifreeze for
more than one year from the date the waste antifreeze was generated
or received from another handler.

Are antifreeze storage containers
and tanks properly labeled? Clearly label or mark each container or tank
of waste antifreeze with any one of the following phrases: "Universal
Waste - Antifreeze," or "Waste Antifreeze," or
"Used Antifreeze."

Is the area around the used
antifreeze storage containers free of releases? Releases must be immediately
stopped, cleaned up and managed properly. Any releases that pose
a threat to human health or the environment must be reported immediately
to DES.

Is used antifreeze transported
to an approved recovery facility? Ensure that all shipments of
used antifreeze were taken to another universal waste handler,
or an authorized antifreeze recycling or hazardous waste facility
by the transporter.

Is oil, solvent or other materials
mixed with used antifreeze? Waste antifreeze mixed with any other material
may lose its ability to be recycled. Do not use collection equipment
and storage containers that have been previously used to collect
other hazardous wastes or materials, unless the equipment has
been decontaminated.

Are filter and sludges being
managed properly? Any filters or sludges generated from the antifreeze recycling process
must be evaluated as to whether they are hazardous wastes and
managed accordingly.

Best
Management Practices (BMPs)

Most
regulations tell you what you have to do to be in compliance, but
they don't explain how to do it. That's where "best management
practices" come into play. BMPs are proven methods that
help you to get into compliance and stay there. The following BMPs
are recommended for used antifreeze storage areas and management
procedures.

Do not mix waste antifreeze with used oil or
other hazardous wastes.

Do not use collection equipment and storage containers
that have been used previously to collect other hazardous wastes
or materials. Store waste antifreeze in structurally sound containers.

Manage antifreeze in a way that prevents the
release of antifreeze to the environment.

Recycling can be done on-site, by hiring a contractor
to come in with a mobile recycling unit, or by shipping the antifreeze
to a recycling facility.

Do not accumulate antifreeze for more than one
year.

Ensure all employees are properly trained with
handling and emergency procedure relating to antifreeze.

Immediately contain all releases of antifreeze
and report any releases that pose a threat to human health or
the environment.

Do not dispose of antifreeze in the trash or
by pouring it down the drain.

Ensure antifreeze is sent to approved recycling
or other facilities.

Keep any records relating to used antifreeze
for at least one year.

Contacts

For more information, contact the New Hampshire DES
Waste Management Division at 603-271-2900.

To report a spill or leak during business hours, call
the DES at 603-271-3899. If after hours or the weekend, call the
New Hampshire State Police Hazardous Material Response at 800-346-4009
(in-state), or 603-271-3636 (out-of-state).